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Letter 133
Reprogramming lines and waste treatment
costs
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I am curious about what is involved in re-programming an
automatic/semi-automatic line with clean technology in mind, i.e.
reducing dragout and water consumption. It is difficult to convince
operators that they can change the line without ruining their
product. Also, I would be interested in where I might find
information on the capital and operating costs for typical waste
water treatment facilities at metal finishing shops.
Alan Gagnet
Reprogramming a programmed hoist line is generally relatively
easy, say two days work on average. But installing additional rinses,
etc., can be a major (and sometimes impractical) undertaking. It is
very difficult to give a canned answer to what is involved since it
depends on how big the tanks are, how old, whether room exists to
extend the line, etc.
The EPA has published costs several times in the development
documents used to support CFR 413, CFR 433, etc. The impacts of such
changes and the associated costs have been severely underestimated by
the EPA repeatedly (which is probably only to be expected since they
don't have to actually do the implementation, and they have a vested
interest in understating the cost of regulation), but they are pretty
much universally available, and so they are a good starting point.
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